Tensions between the EU and the US over tax follow investigations into Apple in Ireland The US should be added to a new European blacklist of tax havens being drawn up by the European Commission, according to a report commissioned by the Green group in the European Parliament. The report,… – Continue reading
Authorities answer OECD call to clamp down on corporate grey area of internal transfer pricing with proposal for tougher reporting standards China is mulling plans to tighten tax reporting requirements on multinationals operating in the country to help close a ¬massive global loophole. If the plan goes ahead, multinationals would… – Continue reading
In August 2015, the Organisation for Economic Co-operation and Development (OECD) published the first edition of the Common Reporting Standard (CRS) Implementation Handbook to provide practical guidance to assist government officials in implementing the Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI and CRS… – Continue reading
The tax treatment of non-domiciled individuals is changing again from April 2017. The changes were first announced in the 2015 Summer Budget, and a Consultation document was issued in September 2015 setting out further details. The proposed changes target three key areas: The taxation of non-domiciled individuals who have been… – Continue reading
Only a week after the so-called Panama Papers burst into the media spotlight early last month, the Canadian government issued a news release vowing to “crack down on tax evasion and tax avoidance.” The leak of a staggering 11.5 million documents from a Panama City law firm promised to reveal… – Continue reading
Unctad thinktank shows firms funnelled $221bn in 2015 through low-tax jurisdictions such as the Netherlands and tax havens in the Caribbean The UN has urged governments to stem the flow of funds to tax havens after companies funnelled $221bn (£152bn) into countries with low tax rates last year. The Netherlands… – Continue reading
Thomson Reuters Checkpoint has just released a special report addressing the European Commission’s Anti-Tax Avoidance Package (ATA) and other global Country-by-Country Reporting (CbCR) developments designed in conformity with the OECD BEPS Action 13 recommendations. The report, BEPS Filing Requirements for Multinationals Under Country-by-Country Reporting, will help multinational enterprises (MNEs) gauge… – Continue reading
On January 27, 2016, 31 Countries (among them Mexico) signed the Multilateral Competent Authority Agreement for automatic exchange of Country-by-Country reports (the “Agreement”) to be received from their taxpayers as part of the implementation of Action 13 of the Base Erosion and Profit Shifting Action Plan issued by the Organisation… – Continue reading
THE Bureau of Internal Revenue (BIR) recently issued Revenue Memorandum Circular (RMC) No. 32-2016 setting the amendments in the provisions of the Philippines-New Zealand tax treaty, which was originally entered into on Oct. 2, 2008. The Protocol includes the following changes: 1. The rate for dividends was changed to a… – Continue reading
On October 5, 2015, the Organization for Economic Cooperation and Development (OECD) issued final tax policy recommendations stemming from its Base Erosion and Profit Shifting (BEPS) project. The reports, endorsed by the G20 Finance Ministers on October 8 and by the G20 leaders at their November 15-16 summit, consist primarily… – Continue reading
THE OECD, IMF, World Bank and the UN have formed a platform for collaboration on tax to improve tax systems around the world and strengthen BEPS’ grip on developing nations. Designing and implementing standards for international tax matters is high on the agenda for the new platform, with the four… – Continue reading
Genesis of CbC Reporting and How it will Affect U.S. Multinational Enterprises Country-by-country (CbC) reporting is essentially exactly what it sounds like: a report that shows every country where a multinational enterprise (MNE) operates and allocates income, earnings and pays taxes. The CbC report regulations proposed by the Internal Revenue… – Continue reading
The French taxman, Le Fisc, has apparently decided to send McDonald’s MCD -0.24% France a tax bill for €300 million ($341 million). It’s not entirely obvious that this is a correct demand: nor, in fact, necessarily a legal one. If there were no European Union and no rules about the… – Continue reading
In amove towards a more progressive taxation policy the revenue officials have set an aggressive target of resolving about 100 transfer pricing issues by signing advance pricing agreements (APAs) with multinationals this fiscal, people close to the development said. The government, through the Central Bureau of Direct Taxes (CBDT), had… – Continue reading
Firms waiting for govt to come out with revised safe-harbour rules Although the conclusion of ahead-of-time transfer pricing agreements gained momentum in FY16, applications foradvance pricing agreements (APAs) with the tax authorities fell to the lowest in four years at 130. This could be attributed to companies, especially those in… – Continue reading
The South African Revenue Service (SARS) has issued draft regulations for the purpose of specifying a new country-by-country (CbC) reporting standard for multinational enterprises (MNEs). Legislative amendments to the Tax Administration Act, 2011, were effected during 2015 in order to implement CbC reporting in South Africa. They implement the OECD’s… – Continue reading
Panama is a tax haven, but Mauritius is one with which India has a comprehensive double tax treaty. This complicates matters more. In popular Indian imagination, a tax haven is generally associated with Switzerland and its numbered bank accounts. But tax havens are numerous, have grown in importance, and are… – Continue reading
Despite best intentions of the government, there have been little or no takers for India-based fund managers In 2015, the Indian government took a commendable step by introducing a new provision in the Income-tax Act, 1961 (i.e. section 9A), to promote India as a fund manager jurisdiction, and to encourage… – Continue reading
The European Commission is looking into advance pricing agreements (APAs) given to financing companies and other businesses to see if they constitute illegal state aid, the MNE Tax news site has reported EU competition commissioner Margrethe Vestager told the European Parliament’s TAXE 2 committee that her office has reviewed 1,000… – Continue reading
US President Barack Obama has warned that “tax avoidance is a big global problem” and urged Congress to take action to eliminate tax loopholes. “A lot of it is legal, but that’s exactly the problem,” he said. His comments come a day after the US Treasury Department announced fresh plans… – Continue reading
Indonesia’s Investment Coordinating Board (BKPM) is warning it will annul the investment permits of foreign companies that are proven to be avoiding payment of taxes. “We are ready to revoke the principal licenses, but to prove a transfer pricing, as a tax-avoidance practice, is not the BKPM’s job. It is… – Continue reading
March 31 — Minnesota Sen. John Marty (DFL) introduced legislation that would require corporations headquartered in 46 tax havens to be subject to the same taxation as domestic companies. While it’s still early in the legislative session—the bill was introduced March 29—a spokeswoman for the Minnesota Chamber of Commerce told… – Continue reading
It’s easy to stoke outrage at multinationals’ low taxes but harder to do something about it. According to the Organisation for Economic Co-operation and Development (OECD) – the so-called rich-countries club – tax avoidance by multinational companies is worth US$100-240 billion a year. That’s 4-10% of total global corporate income… – Continue reading
The number of multinational companies warning investors about the risk of higher taxes doubled in the past year, according to analysis by the Financial Times. Nearly a fifth of the US companies who warned on taxes were technology companies, the Financial Times found in a study of company filings. A… – Continue reading
The Canada Revenue Agency (“CRA”) released its Annual Report to Parliament (“Report”), outlining the CRA’s performance and key statistics for 2014-2015. This article highlights some of the measures that the CRA has undertaken to combat non-compliance. During 2014-2015, the CRA assessed over $1.7 billion in additional taxes owing and identified… – Continue reading
Kenya has received global recognition from the Organisation for Economic Co-operation and Development (OECD), following the appointment of James Karanja, a career Kenyan tax administrator to lead the recently established Tax Inspectors Without Borders (TIWB) Secretariat. TIWB is a global scope initiative, that was launched mid last year at the… – Continue reading
Investors alerted to risks of higher payments as crackdown closes loopholes A global crackdown on tax avoidance has forced a surge of warnings by multinational companies that higher payments are set to hit their earnings. A Financial Times analysis of company filings revealed that more than twice the number of… – Continue reading
The tax office plans to deploy a special unit and team up with the Investment Coordinating Board (BKPM) to probe thousands of foreign firms allegedly failing to pay their due taxes. Finance Ministry taxation director general Ken Dwijugiasteadi said around 2,000 foreign investment companies in various sectors, from industry and… – Continue reading
The Tax Department has signed 11 more Advance Pricing Agreements (APAs) with taxpayers covering overseas transactions within group entities so as to reduce litigations. “Central Board of Direct Taxes (CBDT) has signed 11 unilateral APAs on March 28, 2016. With this signing, India has entered into 59 bilateral and/or unilateral… – Continue reading
The Financial Accountability and Corporate Transparency (FACT) Coalition is urging the Treasury Department to take further action to prevent companies from reincorporating overseas to lower their taxes. “It is time we eliminate this egregious offshore loophole to make sure that the corporations that benefit from all of the resources, protections,… – Continue reading
European Union member states are taking the lead on implementing the Organisation for Economic Co-operation and Development’s recommendations under the base erosion and profit shifting (BEPS) project, a new EY report says. EY’s Outlook for global tax policy in 2016 report highlights that, of the 14 jurisdictions (37 percent) either… – Continue reading
Even as more large companies announce plans to take advantage of the inversion loophole to avoid taxes, Congress has refused to move on commonsense legislation that would put an end to inversions. Fortunately, as outlined in a new letter signed by Citizens for Tax Justice and 54 other groups, there… – Continue reading
Ireland recently announced it will introduce a formal advance pricing agreement (APA) programme this year. Ireland has accepted and concluded bilateral APAs for many years although there have been no formal procedures to initiate an APA in Ireland. However, in light of comments made by an Irish Revenue official at… – Continue reading
The Federation of Korean Industries (FKI) has disclosed that 81 percent of respondents to a survey of South Korean companies professed that, although they were aware of the OECD’s base erosion and profit shifting (BEPS) project, they were not, as yet, making any preparations. The South Korean Government is preparing… – Continue reading
The first Budget tabled by Canada’s new Liberal Government provides for a major crackdown on tax evasion and avoidance, and streamlines the domestic tax credits system. The Budget was delivered by Finance Minister Bill Morneau on March 22, 2016. He told Parliament: “Today, we begin to restore hope for the… – Continue reading
The American Institute of CPAs has written to the Internal Revenue Service recommending some changes in the IRS’s proposed regulations for country-by-country reporting by multinational corporations of financial information to curb tax avoidance. The proposed regulations were issued last December as part of an effort by the Organization of Economic… – Continue reading
Ireland’s 12.5 percent corporate tax rate has encouraged several major U.S. companies like Medtronic, Pfizer, Johnson Controls, and Baxalta to move there in tax inversions in recent months, saving them billions of dollars of taxes and protecting themselves from international competition in the process. The U.S. corporate tax rate, on… – Continue reading
NEW DELHI: India has substantially liberalised the tax framework to extend exemption to fund houses owned by a single institutional entity, a move aimed at attracting offshore fund management activity into the country. The Central Board of Direct Taxes (CBDT), the apex direct taxes body, has announced rules to implement… – Continue reading
The government has signed five more advance pricing agreements with multinational firms. Of these, three are new agreements while two were renewals, according to consulting firm EY, which was involved in three of the deals. An Advance Pricing Agreement, or APA, is essentially a negotiated deal between a taxpayer and… – Continue reading
Summary The pace of change in international tax is dramatic. Each month brings new initiatives and developments at both national and supra-national levels. In this update, we focus on recent changes which are relevant to our clients. The OECD Base Erosion and Profit Shifting (“BEPS”) reports were finalised in October… – Continue reading
In their latest attempt to try to stamp out tax avoidance by multinationals in the European Union, lawmakers are set to question Apple, Google, IKEA and McDonald’s over their tax affairs as EU member states fail to agree a common tax policy. Lawmakers in the EU have struggled to prevent… – Continue reading
THAILAND HAS no plan to adopt any time soon the three-tiered approach to transfer-pricing documentation recommended by the Organisation for Economic Cooperation and Development. However, large Thai multinational enterprises (MNEs) with subsidiaries operating in countries that are members of the OECD and/or Group of 20 will find that they will… – Continue reading
Thomson Reuters Checkpoint has just released a special report, European Commission Presents Anti-Tax Avoidance (ATA) Package, summarizing the ATA Package to help businesses plan for the latest developments in advance of implementation. On January 28, 2016, the European Commission presented its Communication on the Anti-Tax Avoidance Package. The goal of… – Continue reading
State lawmakers are getting into the act of demonizing corporate inversions even though there is not much they can do to stop them. Corporate inversions, in which U.S. companies merge with or are acquired by an overseas business, are a hot topic on the campaign trail and in the halls… – Continue reading
Only the little people pay taxes. For a small, select cohort of rich Australians, the famous quote of New York property billionaire Leona Helmsley rings not as an outrage but as an inspiration. In the most recent documents released by the Australian Tax Office, there were 55 people who had… – Continue reading
The amount of tax multinational companies pay – and the amount they don’t pay – has become highly controversial, writes RTÉ’s Economics Correspondent Sean Whelan. This is mainly as a result of public outrage over legal tax avoidance schemes that big companies can use to shelter vast amounts of money… – Continue reading
It’s not just the Indian banks that business tycoon Vijay Mallya has taken for a ride. The chairman of United Breweries (UB) group and promoter of now defunct Kingfisher Airlines also concealed in his election affidavit, filed before the Rajya Sabha, his business interests in offshore tax havens elsewhere. dna… – Continue reading
EU countries will exchange information on the tax affairs of multinational companies under new rules backed by EU finance ministers aimed at stopping big companies avoiding paying their fair share into government coffers. The rules, that should take effect later this year, are a response to growing concerns about corporate… – Continue reading
With American corporations keeping a record amount of profits offshore to avoid paying U.S. taxes, U.S. Sen. Sherrod Brown (D-OH) will introduce legislation requiring corporations to “Pay What You Owe Before You Go.” During a news conference call today, Brown will outline his bill that would require corporations to settle… – Continue reading
Following the release of the anti-tax-avoidance (ATA) package on January 28, 2016 by the European Commission, the Dutch Presidency of the Council of the European Union presented an EU-Base Erosion and Profit Shifting (BEPS) Roadmap (the Roadmap) to the Members of the High Level Working Party on Tax issues. The… – Continue reading
